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You know, you make a very good point. The more I think about it, why couldnt someone give instrument training to someone who already has a multi instrument ticket? The only problem I see is how do you do the single engine approach training, if you are not a MEI??

Now if we are talking about giving dual to someone who already has a Multi Instrument ticket for the sake of equipement familiraztion (new GPS etc) then I see no problem since you are not training for category, class or instrument you are simply acting as a safety pilot.

Then again all my time giving training was in a 141 school where we trained for both the instrument, commercial and multi engine ratings at once so I am a little mis informed as to doing this in the part 61 world.

Keep it up man, your slowly turning me to the dark side :p
 
AAAAAAH HAAAA! Almost got me to the darkside!

I think, again I think, the whole purpose of subsection (c) is to keep someone from having a Comm ASEL Instrument Airplane with a Multi Engine rating limited to VFR and also having CFI, CFII, MEI from providing instrument instruction in the twin. You could still give private and commercial instruction but not for instrument rating in a twin.

I believe you may be looking at subsection (c) the wrong way. It is not a loop whole to allow CFII(s) to provide instrument training in a twin without a MEI, but it is meant to close the loop hole of not having an instrument rating for the instructors multi engine rating. Likewise vice a versa, say for whatever reason you only have an AMEL Inst Comm and a Comm ASEL and CFI, CFII, MEI you could give instrument twin training but not instrument single engine training.

The problem is, most people go the normal route and get there ASEL Inst Commercial and CFI, CFII, then add the Comm MEL Instrument and MEI later so it really never comes up.

Good discussion though!
 
DC8 Flyer said:
The only problem I see is how do you do the single engine approach training, if you are not a MEI??

I guess my response to that would be that as a CFII you're not teaching him how to fly the airplane with one engine out (the regs assume both you and the student already know how to fly on a single engine). All you're teaching is how to use the instruments to fly the same maneuvers you already know without having the benefit of visual references.

Think of the Cessna 152 example. How can a CFII (who does not hold a CFIA) give instrument flight training to a private pilot in a single-engine airplane? The instructor is not qualified to teach slow flight, steep turns, or even climbs and descents, but he can teach someone to fly by sole reference to instruments.

How's that? That's the best I can do....
 
DC8 Flyer said:
I believe you may be looking at subsection (c) the wrong way. It is not a loop whole to allow CFII(s) to provide instrument training in a twin without a MEI, but it is meant to close the loop hole of not having an instrument rating for the instructors multi engine rating. Likewise vice a versa, say for whatever reason you only have an AMEL Inst Comm and a Comm ASEL and CFI, CFII, MEI you could give instrument twin training but not instrument single engine training.

It's not a loop hole. It's just not very clear.

Now, by your argument if I hold a Comm ASEL and a CFII (no CFI(ASEL) or MEI), then my CFII would be utterly useless. If this was the case, the FAA would impose the same restriction they impose in the Pvt-Ins scenario. You can not earn your Instrument Rating without having a current Private License. The reason they require a current Pvt is not because you don't know how to fly without one, because there are recreational pilots who fly better than even some brand new commercial pilots, but it is because you would not be able to exercise the privileges of an Instrument Rating without a current Pvt License.

If this was the same case with the CFII rating then the FAA would not allow a pilot to test for a license he/she would not be able to use. If I can not teach instruments in a multi-engine airplane without an MEI, then a CFII would not be able to give any instrument flight training without a CFI(ASEL) or MEI.

This we know to be false. A CFII can give instrument flight training without a CFI(ASEL) rating. By the same token a CFII can give flight training in a multi-engine airplane as long as both the instructor and the student are appropriately rated. Furthermore, a CFII who holds an MEI but does not hold a SEL pilot rating can not give instrument flight training in a Cessna 152.

What do you think? You over to the dark side yet?
 
It seems pretty simple to me.

61.195 B says...
You have to have the category and class ratings on your pilot certificate and your instructor certificate.

61.195 C says...
To give instrument rating instruction you have to have an instrument rating on your pilot license and instructor certificate appropriate to category and class.

Let's look at it this way.

1. 61.195 C doesn't say "61.195 B doesn't apply bla bla bla..."
2. You have to have the Commercial MEL and CFI-ME to give instruction in a Multiengine aircraft.
3. You have to have an instrument rating appropriate to category and class to instruct for instruments.
a. Commercial ASEL - IA & CFI - SE - IA
b. Commercial AMEL - IA & CFI - ME - IA

How the CFII only holders work, I have no idea. It says "instrument airplane" on the certificate...but what kind of airplane?

Other than that, it seems very, very simple to me...I agree with nosehair.

Easiest solution...get the MEI. From what I've heard, it's possibly one of the easiest checkrides (which is scarry). Fewest required task areas in the PTS if you've got the CFI/CFII already.

-mini
 
BYUFlyr said:
It's not a loop hole. It's just not very clear.

Now, by your argument if I hold a Comm ASEL and a CFII (no CFI(ASEL) or MEI), then my CFII would be utterly useless.

Wouldnt be worthless because you could only give Instrument instruction, no private or commercial instruction. Because you have an instrument rating on both your Commercial ticket and your CFII ticket. I have no idea how that would be printed on your CFII ticket I have never seen one. I would think it would only say Instrument Airplane, but then that opens the can of works of not having both category and class on both your commercial and instructor ticket so maybe it would say "Single Engine; Instrument Airplane: Instrument Instructor Privelages Only"??

If this was the case, the FAA would impose the same restriction they impose in the Pvt-Ins scenario. You can not earn your Instrument Rating without having a current Private License. The reason they require a current Pvt is not because you don't know how to fly without one, because there are recreational pilots who fly better than even some brand new commercial pilots, but it is because you would not be able to exercise the privileges of an Instrument Rating without a current Pvt License.

If this was the same case with the CFII rating then the FAA would not allow a pilot to test for a license he/she would not be able to use. If I can not teach instruments in a multi-engine airplane without an MEI, then a CFII would not be able to give any instrument flight training without a CFI(ASEL) or MEI.

This we know to be false. A CFII can give instrument flight training without a CFI(ASEL) rating. By the same token a CFII can give flight training in a multi-engine airplane as long as both the instructor and the student are appropriately rated. Furthermore, a CFII who holds an MEI but does not hold a SEL pilot rating can not give instrument flight training in a Cessna 152.

What do you think? You over to the dark side yet?

Now if the student holds a multi engine rating, is where the grey area starts. I was arguing the fact if you are trying to give instrument instruction to someone who doesnt have any multi engine ratings.

If you are giving training to PVT AMEL student for a PVT Inst AMEL rating but you dont have an MEI how do you teach single engine approaches?? The instrument PTS requires single engine work on the checkride. You havent been "trained" to pull engines (not doubting you personally) just like a CFI can not give instrument instruction (for an instrument rating, not the instrument training required for PVT) even though they are instrument rated.

As far as the darkside goes, I would say the lightsabre is turning a light shade of pink
 
Ok, how about we just pull out the trump card:

http://www.faa.gov/library/manuals/examiners_inspectors/8700/volume2/media/2_011_00.pdf

The FAA says you can give instrument flight instruction in a multi-engine aircraft without having an MEI.

A. Single and/or Multiengine Ratings. According to
FAR Par t 6 1 , flight instructors who hold an
“instrument-airplane” rating only
on their flight instructor
certificate are authorized to give instrument flight instruction
in single and/or multiengine airplanes for instrument
certification
, provided they hold single and/or multiengine
ratings on their pilot certificate.


How's that for a trump card?
 
DC8 Flyer said:
If you are giving training to PVT AMEL student for a PVT Inst AMEL rating but you dont have an MEI how do you teach single engine approaches??

You don't teach single engine approaches, he already knows how to do that under VMC. The CFII teaches him how to rely on the instruments to do what the students already knows.

Remember this is instrument flight training not flight training.
 
BYUFlyr said:
I guess my response to that would be that as a CFII you're not teaching him how to fly the airplane with one engine out (the regs assume both you and the student already know how to fly on a single engine).

I would say the regs assume the student knows how to fly on one engine in VFR conditions, you as the instructor are now tasked with teaching the student how to fly on one engine under IMC conditions. The real kicker here is, no single engine instrument testing on the MEI checkride is required.

All you're teaching is how to use the instruments to fly the same maneuvers you already know without having the benefit of visual references.

Think of the Cessna 152 example. How can a CFII (who does not hold a CFIA) give instrument flight training to a private pilot in a single-engine airplane? The instructor is not qualified to teach slow flight, steep turns, or even climbs and descents, but he can teach someone to fly by sole reference to instruments.

You are qualified, however, to teach slow flight, stalls, climbs and descents by sole reference to instruments as a CFII.

How's that? That's the best I can do....

Sorry for additional posts.
 
BYUFlyr said:
Ok, how about we just pull out the trump card:

http://www.faa.gov/library/manuals/examiners_inspectors/8700/volume2/media/2_011_00.pdf

The FAA says you can give instrument flight instruction in a multi-engine aircraft without having an MEI.

A. Single and/or Multiengine Ratings. According to
FAR Par t 6 1 , flight instructors who hold an
“instrument-airplane” rating only on their flight instructor
certificate are authorized to give instrument flight instruction
in single and/or multiengine airplanes for instrument
certification, provided they hold single and/or multiengine
ratings on their pilot certificate.


How's that for a trump card?

Thats a very good trump card, and I was hoping you weren't going to pull it ;)


The thing with that is read the 15. Regulatory Requirements. It seems as though it contradicts itself. Specifically the part thats says, "The phrase "if appropriate" applies equally to and in combination with both certificates when instrument instructor ratings are involved."

As you read on it does give the appearance you can give instruction in a twin without having an MEI for instrument rating BUT paragraph C limits that to if only the student has a multi engine rating. So yup, I was wrong on that one, just had to sit and read it over and over 20 times to get it to set in!

So I guess if your student has his/her PVT AMEL ticket you can give them training in a twin for an instrument rating if you have only a CFII.

Doesnt sound right, but thats what the book says. The lightsabre is getting a little more red:D .
 
DC8 Flyer said:
So I guess if your student has his/her PVT AMEL ticket you can give them training in a twin for an instrument rating if you have only a CFII.

I have to confess I don't have any instrument students nor have I had the opportunity to give instrument training in a multi-egine airplane, just thought it was a good topic to jump into and give my opinion.

I actually wouldn't even consider giving instrument flight training in a multi unless the "student" was a competent multi-rated pilot (I don't have enough multi experience to feel safe pulling an engine on someone who didn't know what they were doing).

Welcome to the dark side.....

Fly safe!
 
Hey! I already played that trump card waaaaay back at the beginning of the thread!

Ah, who cares - just get all the freakin' certificates already. All I've gotta do is get the 15 hours PIC in a multi. THAT's the expensive part.

FF
 
frascaflyer said:
Hey! I already played that trump card waaaaay back at the beginning of the thread!

FF,

You are absolutely right, I can't take the credit for that one. I should've quoted your post.

I don't think the argument was for any practical use, it was just a fun topic to discuss.

Sorry for taking all the glory for your trump card....

Fly safe!
 
You better be sorry! My flight school's estimation of me is based in part on how many flightinfo arguments I can demonstrate that I've won on my own merits. I'm trying to get hired here and you're not helping!

Just kidding. You're right, it's all academic anyway, but don't academic discussions fall under that "continuing education" mandate for CFIs?

Back to my beer.

FF
 
According to the regs, and CFII (with no airplane ratings) can only give ground and simulator instruction. No muli or single instruction.

The applicable regs have already been quoted in this thread, but here they are consolidated:

61.195 (b) Aircraft ratings. A flight instructor may not conduct flight training in any aircraft for which the flight instructor does not hold:

(1) A pilot certificate and flight instructor certificate with the applicable category and class rating

The aircraft ratings in that reg refers to aircraft ratings that the instructor must hold, not that the training is for an aircraft rating. Notice that the meat of the reg makes no reference to what type of training, whereas the next part for instrument training does.

61.195 (c) Instrument Rating. A flight instructor who provides instrument flight training for the issuance of an instrument rating or a type rating not limited to VFR must hold an instrument rating on his or her flight instructor certificate and pilot certificate that is appropriate to the category and class of aircraft in which instrument training is being provided.

Part (c) actually has no bearing on the issue. Everybody seems to agree that the instructor must be a "double-I". However, even if it did, part C still requires that the instrument rating on the instructor certificate be appropriate to the cat/class. There is no ambiguity unless you try to force it to be there.

BYUFlyr said:
If this was the same case with the CFII rating then the FAA would not allow a pilot to test for a license he/she would not be able to use. If I can not teach instruments in a multi-engine airplane without an MEI, then a CFII would not be able to give any instrument flight training without a CFI(ASEL) or MEI.

The CFII is not useless, they can give ground and simulator instruction. Now sure, most people here would find that useless, because you wouldn't be able to build that oh so valuable flight time as a time building CFI. Realize that the CFI was not intended, and should not be, a time builder. The CFI should be someone who cares about teaching people, and such a person would not be turned off by not getting flight time. According to the letter of the law, a CFII can not give instruction in an aircraft.
 
Ralgha said:
The CFII is not useless, they can give ground and simulator instruction.

Exactly!

A bit off topic...but not really...sort of...in a way.

An AGI is authorized to provide instruction for any certificate or rating in "this part" (Part 61). So...does that mean as an AGI/IGI, I can give ground instruction in a multi-engine airplane simulator towards a certificate or rating dealing with multi-engine airplanes?

I would think yes...since that's what the regs says, but I've been told no since I don't hold the CFI-ME.

Any takers on that one?

-mini
 
Sorry Ralgha, incorrect. The language is not specific enough to guarantee the interpretation that you have given.

To wit:

"61.195 (b) Aircraft ratings. A flight instructor may not conduct flight training in any aircraft for which the flight instructor does not hold:

(1) A pilot certificate and flight instructor certificate with the applicable category and class rating"

What's the applicable category and class rating? Does category and class apply to instrument instruction? I don't know. Category probably does - your pilot and flight instructor certificates specify "Instrument Airplane". But class? Is single or multi appropriate to instrument instruction? I don't know. Let's ask the FAA.

"A. Single and/or Multiengine Ratings. According to
FAR Part 61 , flight instructors who hold an
“instrument-airplane” rating only on their flight instructor
certificate are authorized to give instrument flight instruction
in single and/or multiengine airplanes for instrument
certification, provided they hold single and/or multiengine
ratings on their pilot certificate."

Aha!

How about that second reg?

"61.195 (c) Instrument Rating. A flight instructor who provides instrument flight training for the issuance of an instrument rating or a type rating not limited to VFR must hold an instrument rating on his or her flight instructor certificate and pilot certificate that is appropriate to the category and class of aircraft in which instrument training is being provided."

As BYU suggested, it's all in the way you parse the sentence. English doesn't separate clauses all that clearly, so this reg can mean:

"must hold an instrument rating on his or her flight instructor certificate" + "[must hold a] pilot certificate that is appropriate to the category and class of aircraft in which instrument training is being provided."

or it could mean:

"must hold an instrument rating appropriate to category and class on his/her flight instructor and pilot certificates."

Again we ask what category and class is appropriate to instrument training? My pilot certificate says "Instrument Airplane". What does yours say? Still, I'm not so sure. Let's ask the FAA.

"Q&A-641 October 5, 2004

QUESTION: A person holds a Flight Instructor Certificate - Instrument Airplane only and wants to give instrument flight training on avionics in a multiengine land airplane (for example in a Cessna 310). The training that the flight instructor will be giving is not for the purpose of furtherance of a pilot certificate or rating. The training is merely for educational/informative purposes. The instrument flight training will be on: Air Traffic Control Clearances and Procedures - Holding Procedures; Navigation Systems - Intercepting and Tracking Navigational Systems and DMC ARCs; and Emergency Operations - Loss of Communications and Loss of Gyro Attitude and/or Heading Indicators.

What are the flight instructor certificate and ratings, pilot certificate and ratings, and flight experience the person must have to be in compliance with § 61.195(b) and (c)? Does the flight instructor have to have logged 5 hours of PIC flight experience in the Cessna 310?

ANSWER: Ref. § 61.195(b), (c), and (f); The person must hold at least the following:

Flight Instructor Certificate
Instrument-Airplane
&
Commercial Pilot Certificate Instrument-Airplane
Airplane Multiengine Land
or

ATP Certificate
Airplane Multiengine Land

The flight instructor would only have to have logged 5 hours PIC flight time in a Cessna 310 if the training was for the furtherance of a certificate or rating. Since you specifically stated in your question that the training was not for the furtherance of a certificate or rating but was for merely for educational/informative purposes, then the answer is no, the flight instructor would not need to have logged 5 hours PIC flight time in a Cessna 310.
{Q&A 641} "

I see a pattern here. Do you? Regulatory wording that requires interpretation + FAA interpretation = Binding regulation. CFIIs can instruct in airplanes. Period. This simulator and ground instruction only is bogus. I can do that, and all I've got is an AGI and IGI.

FF
 
mini -

Sure you can give ground instruction for a multi-engine rating with an AGI. You can give ground instruction for *anything* in part 61, as you said, with an AGI. That includes instrument ratings. (Before you ask, I got the IGI because I heard somewhere that the wording of the AGI reg was a screwup and they really want to require an IGI for instrument ground instruction, so a change might be forthcoming. Plus it's only an extra $75 or so.) You can even give ground instruction for airships, helicopters, gliders, *everything*. I had a helicopter question on my AGI written.

So it's all legal. Much like the CFII debate above, though, the practical wisdom of me providing lighter-than-air ground instruction to someone - considering I know bupkis about LTA regs - is about the same as me pulling an engine on someone, even though they're a certificated multi pilot. In the airplane I'm worried about becoming a smoking hole in the ground when the guy steps on the wrong rudder. On the ground I'm worried about my signature being in the logbook of some hot air balloon pilot who breaks some reg I've never heard of, or someone who drifts over P-51.

FF
 
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frascaflyer said:
mini -

(Before you ask, I got the IGI because I heard somewhere that the wording of the AGI reg was a screwup and they really want to require an IGI for instrument ground instruction, so a change might be forthcoming. Plus it's only an extra $75 or so.)

Ditto

*edit*
And thanks for clearing that up...

-mini
 
Last edited:
frascaflyer said:
Sorry Ralgha, incorrect. The language is not specific enough to guarantee the interpretation that you have given.

To wit:

"61.195 (b) Aircraft ratings. A flight instructor may not conduct flight training in any aircraft for which the flight instructor does not hold:

(1) A pilot certificate and flight instructor certificate with the applicable category and class rating"

What's the applicable category and class rating? Does category and class apply to instrument instruction? I don't know. Category probably does - your pilot and flight instructor certificates specify "Instrument Airplane". But class? Is single or multi appropriate to instrument instruction? I don't know. Let's ask the FAA.

What's the applicable category and class? Are you kidding me? So, if I hold a private pilot certificate, with ASEL and instrument ratings (no MEL), then I could fly a twin as long as I never looked out side? Look on your pilot certificate, your instrument rating is not specific to a class.

frascaflyer said:
"A. Single and/or Multiengine Ratings. According to
FAR Part 61 , flight instructors who hold an
“instrument-airplane” rating only on their flight instructor
certificate are authorized to give instrument flight instruction
in single and/or multiengine airplanes for instrument
certification, provided they hold single and/or multiengine
ratings on their pilot certificate."


Aha!

That's not the letter of the law.

frascaflyer said:
How about that second reg?

"61.195 (c) Instrument Rating. A flight instructor who provides instrument flight training for the issuance of an instrument rating or a type rating not limited to VFR must hold an instrument rating on his or her flight instructor certificate and pilot certificate that is appropriate to the category and class of aircraft in which instrument training is being provided."

As BYU suggested, it's all in the way you parse the sentence. English doesn't separate clauses all that clearly, so this reg can mean:

"must hold an instrument rating on his or her flight instructor certificate" + "[must hold a] pilot certificate that is appropriate to the category and class of aircraft in which instrument training is being provided."

or it could mean:

"must hold an instrument rating appropriate to category and class on his/her flight instructor and pilot certificates."

It holds the second meaning. If it held the first, then it would say "must hold an instrument rating on his or her flight instructor certificate and a pilot certificate that is appropriate to the category and class

frascaflyer said:
Again we ask what category and class is appropriate to instrument training? My pilot certificate says "Instrument Airplane". What does yours say? Still, I'm not so sure. Let's ask the FAA.

"Q&A-641 October 5, 2004

QUESTION: A person holds a Flight Instructor Certificate - Instrument Airplane only and wants to give instrument flight training on avionics in a multiengine land airplane (for example in a Cessna 310). The training that the flight instructor will be giving is not for the purpose of furtherance of a pilot certificate or rating. The training is merely for educational/informative purposes. The instrument flight training will be on: Air Traffic Control Clearances and Procedures - Holding Procedures; Navigation Systems - Intercepting and Tracking Navigational Systems and DMC ARCs; and Emergency Operations - Loss of Communications and Loss of Gyro Attitude and/or Heading Indicators.

What are the flight instructor certificate and ratings, pilot certificate and ratings, and flight experience the person must have to be in compliance with § 61.195(b) and (c)? Does the flight instructor have to have logged 5 hours of PIC flight experience in the Cessna 310?

ANSWER: Ref. § 61.195(b), (c), and (f); The person must hold at least the following:

Flight Instructor Certificate
Instrument-Airplane
&
Commercial Pilot Certificate Instrument-Airplane
Airplane Multiengine Land
or

ATP Certificate
Airplane Multiengine Land

The flight instructor would only have to have logged 5 hours PIC flight time in a Cessna 310 if the training was for the furtherance of a certificate or rating. Since you specifically stated in your question that the training was not for the furtherance of a certificate or rating but was for merely for educational/informative purposes, then the answer is no, the flight instructor would not need to have logged 5 hours PIC flight time in a Cessna 310.
{Q&A 641} "

This is from the Part 61 FAQ, which holds no legal weight at all.

frascaflyer said:
I see a pattern here. Do you? Regulatory wording that requires interpretation + FAA interpretation = Binding regulation. CFIIs can instruct in airplanes. Period. This simulator and ground instruction only is bogus. I can do that, and all I've got is an AGI and IGI.

FF

I agree, but the letter of the law says otherwise, and personally I think allowing anyone who doesn't hold the cat/class rating on their CFI ticket to teach in an airplane is BS. Before you go an do it, you should probably talk to your insurance company as well, I'm sure they'd love to have a CFI without ASEL OR AMEL giving instruction.
 

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